IN THE COURT OF THE DISTRICT AND SESSIONS JUDGE OF

CHITTOOR

Crl.M.P.No. OF 2014
CRIME No. 100 OF 2014
(I TOWN P.S., CHITTOOR)

BETWEEN:

K.Pethiraju Nadar, aged 35 years,

S/o Karpaswamy Nadar, Hindu, Business,
R/a No.127, 3rd Cross, Pragathipura,
Bangalore, (showned wrong address),

Residing at Etteri Village,

GD Nellore Mandal, Chittoor District. … Petitioner/A.1

AND:

S.H.O., of I Town P.S., … Respondent/Complainant

PETITION FILED ON BEHALF OF THE PETITIONER/ACCUSED No.1 UNDER

SEC.438 OF Cr.P.C.

-oOo-

1. It is submitted that the petitioners is alleged as Accused No.1 in the above

case and he is law abiding citizens.

2. It is submitted that the respondent/de-facto complainant registered the above

case for an alleged offence punishable under Sec.7(1) Essential Commodities Act, r/w
(2) K & 3 of A.P. Scheduled Commodities Licensing Storage & Regulation Act, 2008
and the respondent/police illegally arrested the accused No.3 to 5 and they were
produced before the IV A.D.M.M., of Chittoor on 06.06.2014 and they were released on
bail on the same day on 06.06.2014.

3. It is further submitted that brief facts of the alleged case of the that on
06.06.2014 at 1.00 pm., backside of old RTO Office, Industrial Estate, Chittoor, wherein
the Sub Inspector of Police, I Town P.S., Chittoor arrested the accused A.3
S.B.Mahaboob Basha, A.4 V.Gunasekhar, A.5 Reddeppa while they smuggled boiled
rice of A.1 Pethiraju Nadar from one lorry to another to transport the same to Karnataka
State without any valid license and seized 3 lorries bearing Reg. Nos.(1) AP16-TW-
6791, (2) KAO5-AA-5153 (3) AP21-TU-1368, one Mahindra Max Truck bearing
Reg., No.TN25-L-8587 along with 400 bags of boiled rice, each bag contains weighing
about 50 kgs and boiled rice brought in Maxi truck vehicle under a cover of mahazar,
hence the FIR.

4. It is further submitted that the petitioner/A.1 is law abiding citizen and he was
no where connected to the above case and not committed any offence much less
offence as alleged by the respondent/police, he was falsely implicated in the above
case. It is further submitted that the entire allegations in the complaint are utterly false
and invented for the purpose of implicating the petitioner/A.1 in the above case.

5. It is further submitted that the petitioner/A.1 is actually residing in the above

said address at Etteri Village, G.D.Nellore Mandal and Chittoor District, but the
respondent/police wantonly showned the address of the petitioner/A.1 is residing at
Bangalore which was showned in the FIR is no where concern to the petitioner/A.1 and
he never lived in the said address.

6. It is submitted that the alleged offence registered by the respondent/police

against the petitioner/A.1 vehicle bearing Nos. KAO5-AA-5153 and AP21-TU-1368 are
belongs to the petitioner/A.1 and he is not transporting the alleged goods as alleged by
the respondent/police and there is no stock in the said two vehicle at the time of alleged
arrest of the accused and the petitioner/A.1 or his vehicle never involved in the said
alleged crime as alleged by the respondent/police.

7. It is further submitted that this is the 1 st application and no similar application

is not yet filed in any other.

8. It is submitted that the respondent/police are making hectic efforts to

apprehend the petitioner/Accused No.1 in connection with the above alleged crime, if he
is arrested he will be put to ignominy and sham in the eye of public. It is further
submitted that the petitioner/Accused is ready to produce sufficient sureties to the
satisfaction of this Hon’ble court and he is ready to what ever any conditions imposed
by the Hon’ble Court. It is further submitted that the petitioner/Accused having wife and
two small children and also old aged parents are depending upon the petitioner/A.1 and
the the respondent/police are harassing the family members of the petitioner/A.1and if
he is arrested by the respondent/police, there is no male members to look after the
welfare of his family.

9. It is therefore prayed that this Hon’ble Court may be pleased to, grant
anticipatory bail to the petitioner/Accused No.1 in the event of arrest of the
petitioner/Accused No.1 by the respondent/complainant and pass such other and further
orders in the interest of justice.

ADVOCATE FOR THE PETITIONER/

ACCUSED No.1

NOTE: This is the 1st application and no similar application is not yet filed in any other
court.

Encl: Copy of FIR & Report in Cr.No.100/2014 of I Town P.S., Chittoor.

 IN THE COURT OF THE DISTRICT AND SESSIONS JUDGE OF
CHITTOOR

Crl.M.P.No. OF 2014
CRIME No. 100 OF 2014
(I TOWN P.S., CHITTOOR)

BETWEEN:

Mahmad @ Shaik Mohammad Basha,

Aged 22 years, S/o Shaik Khadar Basha,
Muslim, residing at Nagarchi Palem Village,
Srikalahasti Mandal, Chittoor District. … Petitioner/A.2

AND:

S.H.O., of I Town P.S., … Respondent/Complainant

PETITION FILED ON BEHALF OF THE PETITIONER/ACCUSED No.1 UNDER

SEC.438 OF Cr.P.C.

-oOo-

1. It is submitted that the petitioners is alleged as Accused No.2 in the above case and he is
law abiding citizen.

2. It is submitted that the respondent/de-facto complainant registered the above case for an
alleged offence punishable under Sec.7(1) Essential Commodities Act, r/w (2) K & 3 of A.P.
Scheduled Commodities Licensing Storage & Regulation Act, 2008 and the respondent/police
illegally arrested the accused No.3 to5 and they were produced before the IV A.D.M.M., of
Chittoor on 06.06.2014 and they were released on bail on the same day on 06.06.2014.

3. It is further submitted that brief facts of the alleged case of the that on 06.06.2014 at 1.00
pm., backside of old RTO Office, Industrial Estate, Chittoor, wherein the Sub Inspector of
Police, I Town P.S., Chittoor arrested the accused A.3 S.B.Mahaboob Basha, A.4 V.Gunasekhar,
A.5 Reddeppa while they smuggled boiled rice of A.1 Pethiraju Nadar from one lorry to another
to transport the same to Karnataka State without any valid license and seized 3 lorries bearing
Reg. Nos.(1) AP16-TW-6791, (2) KAO5-AA-5153 (3) AP21-TU-1368, one Mahindra
Max Truck bearing Reg., No.TN25-L-8587 along with 400 bags of boiled rice, each bag contains
weighing about 50 kgs and boiled rice brought in Maxi truck vehicle under a cover of mahazar,
hence the FIR.

4. It is further submitted that the petitioner/A.2 is law abiding citizen and he was no where
connected to the above case and not committed any offence much less offence as alleged by the
respondent/police, they were falsely implicated in the above case. It is further submitted that the
entire allegations in the complaint are utterly false and invented for the purpose of implicating
the petitioner/A.2 in the above case.
5. It is submitted that the alleged offence registered by the respondent/police against the
petitioner/A.2 that he is the driver of the alleged vehicle and the petitioner/A.2 submit that he is
not at all the driver of the vehicle bearing No.AP16-TW-6791 and he is not transporting the
alleged goods as alleged by the respondent/police. It is further submitted that he is no where
connection to the alleged offence as alleged by the respondent/police.

6. It is further submitted that this is the 1st application and no similar application is not yet
filed in any other.

7. It is submitted that the respondent/police are making hectic efforts to apprehend the
petitioner/Accused No.2 in connection with the above alleged crime, if he is arrested he will be
put to ignominy and sham in the eye of public. It is further submitted that the petitioner/Accused
is ready to produce sufficient sureties to the satisfaction of this Hon’ble court and he is ready to
what ever any conditions imposed by the Hon’ble Court. It is further submitted that the
petitioner/Accused having old aged parents and also un married sister who are depending upon
the petitioner/A.2, if he is arrested by the respondent/police, there is no male members to look
after the welfare of his family. It is further submitted that the now the respondent/police is
harassing the petitioner’s/accused No.2’s family members and they are sincerely trying to arrest
the petitioner/A.2.

8. It is therefore prayed that this Hon’ble Court may be pleased to, grant anticipatory bail to
the petitioner/Accused No.2 in the event of arrest of the petitioner/Accused No.2 by the
respondent/complainant and pass such other and further orders in the interest of justice.

ADVOCATE FOR THE PETITIONER/

ACCUSED No.2

NOTE: This is the 1st application and no similar application is not yet filed in any other court.

Encl: Copy of FIR & Report in Cr.No.100/2014 of I Town P.S., Chittoor.

IN THE COURT OF THE DISTRICT AND SESSIONS JUDGE OF

CHITTOOR

Crl.M.P.No. OF 2014
CRIME No. 100 OF 2014
(I TOWN P.S., CHITTOOR)

BETWEEN:

Narayana Pujari, aged about years,

S/o Guruswamy Reddy, Hindu,
Owner of lorry bearing No.AP16-TW-6791,
Thimma Bhupalapuram Village, Pallamala,
B.N.Kandriga, Srikalahasti, Chittoor District. … Petitioner

AND:
 S.H.O., of I Town P.S., … Respondent/Complainant

PETITION FILED ON BEHALF OF THE PETITIONER/OWNER OF THE

VEHICLE BEARING No.AP16-TW-6791 UNDER SEC.438 OF Cr.P.C.

-oOo-

1. It is submitted that the petitioner is owner of the vehicle bearing

AP16-TW-6791 and he is law abiding citizen.

2. It is submitted that the respondent/de-facto complainant registered

the above case for an alleged offence punishable under Sec.7(1) Essential
Commodities Act, r/w (2) K & 3 of A.P. Scheduled Commodities Licensing
Storage & Regulation Act, 2008 and the respondent/police illegally arrested
the accused No.3 to5 and they were produced before the IV A.D.M.M., of
Chittoor on 06.06.2014 and they were released on bail on the same day on
06.06.2014.

3. It is further submitted that brief facts of the alleged case of the that on
06.06.2014 at 1.00 pm., backside of old RTO Office, Industrial Estate,
Chittoor, wherein the Sub Inspector of Police, I Town P.S., Chittoor arrested
the accused A.3 S.B.Mahaboob Basha, A.4 V.Gunasekhar, A.5 Reddeppa
while they smuggled boiled rice of A.1 Pethiraju Nadar from one lorry to
another to transport the same to Karnataka State without any valid license
and seized 3 lorries bearing Reg. Nos.(1) AP16-TW-6791, (2) KAO5-AA-5153
(3) AP21-TU-1368, one Mahindra Max Truck bearing Reg., No.TN25-L-8587
along with 400 bags of boiled rice, each bag contains weighing about 50 kgs
and boiled rice brought in Maxi truck vehicle under a cover of mahazar,
hence the FIR.
4. It is further submitted that the petitioner is law abiding citizen and he
was no where connected to the above case and not committed any offence
much less offence as alleged by the respondent/police, they were falsely
implicated in the above case. It is further submitted that the entire
allegations in the complaint are utterly false and invented for the purpose of
implicating the petitioner’s vehicle in the above case and the
respondent/police are falsely implicated his vehicle in the above alleged
crime and his vehicle was never involved in the above alleged crime as
alleged by the respondent/police and never transported the alleged rice.

5. It is submitted that the alleged offence registered by the

respondent/police the petitioner’s vehicle never transporting the alleged
goods as alleged by the respondent/police and there is no stock in the said
vehicle at the time of alleged arrest of the accused No.3 to 5 and the
petitioner’s vehicle never involved in the said alleged crime as alleged by the
respondent/police. Now the respondent/police are trying to implicate the
petitioner as accused in the above alleged crime.

6. It is further submitted that this is the 1 st application and no similar

application is not yet filed in any other.

7. It is submitted that the respondent/police are making hectic efforts to

apprehend the petitioner/owner of the vehicle in connection with the above
alleged crime, if he is arrested he will be put to ignominy and sham in the
eye of public. It is further submitted that the petitioner/owner of the vehicle
is ready to produce sufficient sureties to the satisfaction of this Hon’ble court
and he is ready to what ever any conditions imposed by the Hon’ble Court.
It is further submitted that the petitioner/owner of the vehicle having, wife
and children and old aged parents who are depending upon the
petitioner/owner of the vehicle, if he is arrested by the respondent/police,
there is no male members to look after the welfare of his family.

8. It is therefore prayed that this Hon’ble Court may be pleased to, grant
anticipatory bail to the petitioner/owner of the vehicle in the event of arrest
of the petitioner/owner of the vehicle by the respondent/complainant and
pass such other and further orders in the interest of justice.

ADVOCATE FOR THE PETITIONER/

OWNER OF THE VEHICLE
st
NOTE: This is the 1 application and no similar application is not yet filed in
any other court.

Encl: Copy of FIR & Report in Cr.No.100/2014 of I Town P.S., Chittoor.